Medicare Part D CGDP - Updated Payment Information for High Dollar Invoice Line Items

CMS has recently identified a limitation with the system when a payment exceeds the threshold of $99,999,999.99. Amounts greater than that exceed the National Automated Clearing House Association (Nacha) size limit for automated clearing house (ACH) payments in the CGDP Portal. Any single invoice line item that is equal to or exceeds $100M will be referred to as a high dollar invoice line item. 

To address this limitation, CMS has implemented a new feature in the CGDP Portal to allow payments for high dollar invoice line items to be completed. When a high dollar invoice line item is present in an invoice reporting period, the original invoice line item will be equally split into two invoice line items and will be formatted in bold to stand out from the other line items. As a result, Manufacturers may receive what appear to be duplicate invoice line items payable to the same sponsor in a specific quarter, and sponsors may receive what appear to be duplicate invoice line item payments from a manufacturer in a specific quarter. These are not duplicate invoice line items.

• If the $100M+ high dollar invoice line item is an even dollar amount, the split line items will be the same, i.e. appear to be duplicates.
• If the $100M+ high dollar invoice line item is an odd dollar amount, there will be a $0.01 difference in between the split line items.

Manufacturers can locate additional information in the CGDP Manufacturer Portal Payments Users Guide found on the TPA website under the “references” section and Sponsors can locate additional information in the CGDP Sponsor Portal Payments Users Guide found on the TPA website under the “references” section.

To review the HPMS memo released by CMS, users with access to HPMS can use this link (https://hpms.cms.gov/app/ng/home/) to access the HPMS memo.

If you have any questions, please contact the TPA by phone at 1-877-534-2772, option 1 or by email at tpaoperations@tpadministrator.com.